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A Fossil-Forward U.S. Energy Policy Begins to Take Shape under Trump

President Trump began his second term by issuing a barrage of executive orders, memoranda, and other directives, many of which targeted U.S. energy policy and the federal employees who implement it. Trump had campaigned on...more

Updated Hydrogen Emissions Model Provides Key Insights into Biogas and Fugitive Methane Feedstock Emissions

On January 15, 2025, Department of Energy (DOE) released updated versions of the 45VH2-GREET lifecycle greenhouse gas (GHG) emissions model and accompanying instructional manual. The updates are crucial to the Inflation...more

Treasury Finalizes Rules for Clean Hydrogen Production Tax Credit (Section 45V)

Over a year since Treasury released proposed rules—after thousands of public comments and various hearings, think pieces, whitepapers, Op-Eds, and, yes, even TV commercials—on January 3, 2025, Treasury finalized rules for...more

Hydrogen Tax Credit Guidance to Be Finalized by Year’s End; Department of Energy Opens Emissions Value Request Process for Clean...

After months of waiting to see how federal regulators might advance clean hydrogen tax policy in the runup to and following the November election, we are finally getting some news: Several outlets are reporting that the...more

Treasury and IRS Issue Guidance on Calculating Lifecycle GHG Emissions for IRA’s Sustainable Aviation Fuel Tax Credit

The IRA created substantial tax credits for SAF. Under Section 40B, SAF producers who meet certain requirements can claim a credit of at least $1.25 per gallon of SAF. Among other things, eligible SAF must achieve lifecycle...more

IRS Issues Guidance and Requests Comment on Provisional Emission Rate Process for Hydrogen Tax Credit

On April 10, 2024, Department of Treasury and the Internal Revenue Service (collectively, “IRS”) issued further guidance on the “Provisional Emission Rate” or “PER” process for the Inflation Reduction Act’s (“IRA”) Hydrogen...more

IRS Releases Guidance on SAF Tax Credit and Signals Forthcoming Revisions to GREET Model for Determi

On December 15, 2023, IRS published Notice 2024-06, a brief but important guidance on Section 40B, the Inflation Reduction Act (“IRA”) tax credit for sustainable aviation fuel (“SAF”). The guidance establishes a safe harbor...more

Department of Energy Chooses Seven Regions for $7 Billion in Hydrogen Hubs Funding

This morning, the Department of Energy decided how it will allocate up to $7 billion of Bipartisan Infrastructure Law (“BIL”) funding set aside for establishing regional Hydrogen Hubs....more

Energy Department Launches Hydrogen Interagency Taskforce, But Few Details Emerge on Status of Federal Hydrogen Programs

The Department of Energy (“DOE”) held a webinar on Friday, August 18, 2023 on the U.S. government’s national hydrogen strategy. The main announcement was the formation of the Hydrogen Interagency Taskforce, or “HIT,” but the...more

Proposed NEPA Rules Address Climate Change, Environmental Justice, and Efficiency of Environmental Reviews

On July 28, 2023, the Council on Environmental Quality (CEQ) proposed reforms to the National Environmental Policy Act (NEPA) regulations governing how federal agencies review the environmental effects of major federal...more

DOE Considers $1 Billion Program to Spur Demand for Clean Hydrogen and Seeks Stakeholder Input

[This is the fifth post in our Hydrogen Blog Series...] The Bipartisan Infrastructure Law appropriated $8 billion for developing Hydrogen Hubs—regional networks to produce, distribute, and use clean hydrogen to curb...more

EPA Proposes New Power Plant Rule That Promises Major Greenhouse Gas Emissions Reductions in the Coming Years

After weeks of hints and leaks, yesterday morning (May 11, 2023), EPA proposed a new rule regulating emissions from power plants. The proposed rule would apply to new and existing gas plants and existing coal plants—new coal...more

Healey-Driscoll Administration Launches Two Commissions to Accelerate Clean Energy Development

It’s a well-worn cliché that siting clean energy projects in Massachusetts is difficult. The statutes, regulations, and permitting processes intended to protect the Commonwealth’s environment and communities can also slow...more

EPA Looks to Accelerate Electric Vehicle Adoption with New Vehicle Emission Standards

On April 12, 2023, the Environmental Protection Agency (EPA) proposed new pollutant emissions standards for light-duty and medium-duty vehicles and heavy duty vehicles.  The proposed rules set new, aggressive greenhouse gas...more

Introducing Our Blog Series on Clean Hydrogen

We’re launching this blog series to help readers keep pace with the fast-moving world of clean hydrogen.  Each week or so we’ll post an article on different legal, regulatory, and technical opportunities and challenges facing...more

CEQ Issues NEPA Climate Guidance

The new year brings new NEPA (interim) guidance on climate change. It recommends several ways that federal agencies should consider climate change impacts for projects subject to NEPA review. The guidance is effective...more

EPA Proposes Major Biofuels Regulation

On December 1, 2022, the Environmental Protection Agency (“EPA”) proposed a sweeping new rule for the Renewable Fuel Standards (“RFS”) Program, the federal government’s flagship program for facilitating the production of...more

West Virginia v. EPA Limits the Federal Government’s Power to Promote Clean Energy and Combat Climate Change

The Supreme Court decided West Virginia v. EPA on Thursday, June 30, 2022, curbing the power of the Environmental Protection Agency (EPA) to regulate greenhouse gas emissions from power plants across the country. The...more

Infrastructure Investment and Jobs Act Part 2: Investing in Transmission

This is the second post in our series on the recently enacted Infrastructure Investment and Jobs Act, covering how the Act invests in strengthening our electric grid, which could better prepare us for the shift from fossil...more

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